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29 October 2008
Tracey Godwin
PO Box 344 Hunter Regional Mail Centre,
NSW 2310
Dear Ms. Godwin,
Re: Applications for Exploration Licenses by Energie Future Pty Ltd under the Commonwealth Offshore Minerals Act 1994
The Nature Conservation Council of New South Wales welcomes the opportunity to comment on the applications for Exploration Licenses by Energie Future. Recently, Energie Future Pty Ltd has submitted four applications to explore for coal deposits in the seabed in Commonwealth waters ranging from Wollongong to Newcastle. The company is using the highly experimental mining method of offshore underground coal gasification (UCG).
Offshore UCG
While it is commonly acknowledged that UCG can allow access to otherwise unattainable offshore coal resources there has been little research done to examine the environmental impacts that may occur when this technology is applied under the sea bed. We feel that these impacts must be thoroughly investigated before large scale exploration (and subsequent extraction) is pursued.
Environmental Issues
Impacts to Marine Life
The 5940 km² exploration zone application for mining spans 135km along the coast of NSW from Royal National Park to Port Stephens. If approved the exploration would expand to a few kilometres from the coast of Sydney to Lake Macquarie and Stockton Brights, areas which are rich in marine life and often see large numbers of migratory whales. The risks of oil spills and leaks from construction and operations of the platforms, pipelines, and shipping would be a threat to marine life in this area.
The effects from seismic testing used in the exploration method could disrupt whale migratory patterns in the area, which would have a direct effect on the tourism industry.
Groundwater
UCG can lead to increased pollutants, such as organic phenols, inorganic ions and other pyrolysis products, leaking into the surrounding groundwater , . We feel that there should be an ongoing effort to prevent ground water leakage from the site. This should continue even after the plant is decommissioned as otherwise the effects can be widespread and persistent .
Subsidence
Subsidence is a potential result of the UCG . It has been shown that subsidence can have damaging effects upon surface ecological communities on land . There is little research done regarding the impacts subsidence may have on marine communities. We want assurances that subsidence is prevented or minimised so that potential impacts upon these communities is reduced or eliminated. Another concern is that subsidence could lead to the reopening of faults, or the starting of underground fires . Subsidence, opening of faults, or underground fires could lead to the release of toxic gases , or previously sequestered CO2 into the surrounding seawater.
Regulations and Legal Conditions
Regulations
The Nature Conservation Council is opposed to this project going ahead based on environmental grounds and the effect that it will have on the marine and coastal environment. However, if this project does get approved by federal government specific policies and frameworks need to be developed and implemented before this project proceeds. Well informed site selection guidelines to ensure a robust site selection process need to be developed. Water quality, gas and pollutant emission guidelines need to be defined. Minimum amounts of pre-combustion CO2 filtration should also be defined. There should be conditions requiring that liquid accumulations of un-dissolved pyrolysis products are removed . There should terms of liability for the person or company responsible for any environmental damage (immediate or eventual) caused as a result of production.
Legal Conditions
Conditions 3 (g) and 3 (h) of section 118 of the Offshore Minerals Act 1994 (Com) should be applied to any exploration licenses granted. These conditions would require Energie Future Pty Ltd to (1) take preventative steps to avoid environmental damage and (2) repair any incidental damage.
We also feel that Regulation 14 of State Environmental Planning Policy (Mining, Petroleum Production and Extractive Industries) 2007 (NSW) should also be considered in relation to the submission made by Energie Future Pty Ltd.
Conclusion
While UCG may represent an improvement on the carbon emissions of the current coal fired industry, it is nonetheless a non-renewable resource technology that does little to achieve long term sustainability goals. Ultimately, any venture into non-renewable energy needs to be paired with significant investment into its renewable counterparts. Intellectual and infrastructural contributions to renewable energies such as solar, wind and tidal power need to be made at a comparable level. Without these concessions, ventures such as these are irresponsibly failing to uphold the principles of ecological sustainable development.
References 1 Ghose, M. & Paul, B. (2007) ‘Underground coal gasification: a neglected option’ International Journal of Environmental Studies, 64(6):777-783. 2 Liu, S-Q, Li, J-G, Mei, M, Dong, D-L. (2007) ‘Groundwater Pollution from Underground Coal Gasification’, Journal of China University of Mining and Technology, 17(4): 0467-0472. 3 Ghose, M. & Paul, B. (2007) ‘Underground coal gasification: a neglected option’ International 4 Journal of Environmental Studies, 64(6):777-783. Klimentov P P. (1964) ‘Influence of groundwater on the process of underground coal gasification,’ Izv Vyssh Ucheb Zavendenii 5 Geologiya Ixazvedka, 4: 106–119.
Gregg, D.W. (1977) Ground subsidence resulting from underground coal gasification, Lawrence Livermore National Laboratory, Livermore, CA, UCRL-52255.
6 Ko, J-Y, & Day, J.W. (2004) ‘A review of ecological impacts of oil and gas development on coastal ecosystems in the Mississippi Delta’, Ocean and Coastal Management, 47(11-12): 597-623.
7 Donnelly, L.J. (2000) ‘Reactivation of geological faults during mining subsidence from 1859 to 2000 and beyond’ Mining Technology: IMM Transactions section A, 109(3): 179-190.
8 Sengupta, M (1993), The Environmental Impacts of Mining: Monitoring, Restoration and Control, CRC Press.
9 Gregg, D.W. (1977) Ground subsidence resulting from underground coal gasification, Lawrence Livermore National Laboratory, Livermore, CA, UCRL-52255.
10 Burton, E, Friedmann, J.& Upadhye, R., Best Practices in Underground Coal Gasification, Lawrence Livermore National Laboratory, https://eed.llnl.gov/co2/pdf/BestPracticesinUCG-draft.pdf (draft accessed 28.10.2008)
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